Become a Member
Membership
Education
Events
Resources
Tax Knowledge Exchange
About us
Contact us
  Miscellaneous 2010

Thin capitalisation, transfer pricing and debt deductions

Source: New South Wales

Published Date: 18 May 2010

 

Sorry, this is subscriber only content.

If you're not yet a subscriber, to gain access to this material and much more - Subscribe Now.

Already a Subscriber? Login now

Subscribe Now

Already a Subscriber? Login now

This paper covers:
  • the interaction of the thin capitalisation rules with the domestic transfer pricing rules
  • can the applicability of a DTA containing an associated enterprises article affect the analysis?
  • what impact does parental affiliation have?
  • what impact do parental guarantees have?
  • what level of protection does the rule of thumb concession provide?
Author(s)

Individual Session

Thin capitalisation, transfer pricing and debt deductions

Author(s): James Nickless , Christian Holle ATI , Robert Pfeiffer
Materials from this session:

Download

Details

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.

Tags

Miscellaneous 2010

Share this page